#337 - Risk Assessment In The Northern Rockies, 12-May-1993

Editor's note: Most of us encounter risk assessment in the context of a
dispute over waste disposal technologies and/or toxic exposures. But
during the past 15 years risk assessments have come to be used
throughout our society to justify all sorts of decisions that have been
made for narrow purposes. Risk assessment is now routinely used to
justify decisions about land use and resource allocation in the western
states. The argument that Dr. O'Brien develops, that it is time to
consider "alternatives assessment" instead of "risk assessment" as a
guide for decision-making, applies to toxics as well.

Much of my work over the last ten years has been with alternatives to
use of toxics: pesticides throughout society, chlorine in the pulp and
paper industry, and currently the potent ozone depleting fumigant,
methyl bromide.

During these years, I have come to hate the use of risk assessment,
which is used obsessively in the U.S. to determine how much of a toxic
substance will be dumped into the world: How much pesticide will be
allowed on the apples you eat; how much dioxin a company like Stone
Container can dump in the Clark Fork River; the size of an air
pollutant permit one company can buy from another in a polluted urban
area. Now the U.S. Environmental Protection Agency is aggressively
teaching other countries like Mexico and the Ukraine how to do
quantitative risk assessment so that everyone will use the same
language for global free trade in toxics.

The whole point of risk assessment is to determine how much damage
people will be permitted to do in the world. The alternative, largely
ignored, is to figure out how LITTLE damage people can do to the world.

But risk assessment is not confined to toxics, and I want very briefly
to describe five behaviors characteristic of risk assessors and then
relate these to what risk assessors do in the world of natural
resources and wildlands. These can be risk assessors in the Forest
Service, Bureau of Land Management, Sierra Club, Audubon Society, or
other agency or big environmental group.

1. Toxics risk assessors act as if they know what damage a toxic
chemical does, and as if they can, on the basis of this knowledge,
determine some safe or "insignificant" level of exposure to the toxic.
But of course they don't know this. They may know what kind of chronic
damage or birth defects a single chemical causes in a genetically pure
line of healthy laboratory rats. They generally have no information on
whether it causes immune suppression, endocrine disruption, or nerve
damage in infants; or chronic damage in people who already are damaged
in some other way.

2. Toxics risk assessors focus on one chemical at a time. When I
recently asked the Director of the National Institutes for
Environmental Health Sciences about the possibility of switching the
focus of the National Toxicology Program from testing a handful of
individual chemicals for cancer a year to looking at types of mixtures
of chemicals faced by people living near multiple industries or
incinerators or hazardous waste dumps, he indicated that studying
mixtures of chemicals is "too hard." The problem, however, is that we
and wildlife are exposed to mixtures of chemicals and indeed are born
with them, our mothers having passed on many to us.

3. Toxics risk assessors focus on whether the world can withstand a
particular activity. The assessors try to figure out, for instance,
whether you will survive if Stone Container uses chlorine to make
cardboard blinding white. They may ask whether fish at the end of the
mill's nine-mile "mixing zone" will be able to reproduce.

4. Toxics risk assessors decide what levels of risk and damage and
killing are acceptable for other people. But can anyone decide an
acceptable risk for you? Isn't it premeditated murder to give permits
to industries with the estimate that one in 100,000 people will get
cancer? Other, perhaps more vulnerable, species are seldom considered
in the permits.

5. Toxics risk assessors focus on the risks and damages caused by
business-as-usual, not business-as-it-could-be. The alternative to
determining how much damage people will be permitted to do in the world
is to determine how little damage people COULD do in the world.

Let's look at the analogous activities of risk assessors in the world
of wildlands, wildlife, and natural resources, and what they could do
differently.

1. Land management risk assessors assume they know what damage
clearcutting or road-building or grazing or pesticide spraying or
mining does to an ecosystem's web of life. Do Forest Service risk
assessors know what is happening to bats on lands they oversee? Do they
know the needs of rare butterflies on that land? Do they know what
organochlorines are doing to reproductive success of Peregrine Falcons?
Land managers and users need to admit they don't know enough to say
what human activity is safe. They can only have an inkling of the
damage humans do. They don't know what the rare butterflies and the
bats need. They don't even know what butterflies and bats are out
there.

2. Land management risk assessors focus on one activity, one timber
sale, one stream, maybe one watershed, or one Congressional bill at a
time. Do the risk assessors know what happens when a watershed is
subjected to grazing and clearcutting and pesticides and road-building
at the same time? Do they know what happens when Peregrine Falcons are
faced with reduction in prey and loss of solitude and organochlorines
in the food chain, all at once? Land managers and users need to focus
on cumulative effects and the interdependence of various elements of
the ecosystem. Cumulative effects are often impossible to quantify; and
risk assessors get nervous when they can't reduce decisions to numbers.
Yet, effects are cumulative.

3. Land management risk assessors focus on whether the land can
withstand a certain action. For a year and a half, the Wallowa-Whitman
National Forest convened a citizens committee to suggest management of
the Snake River. The committee was called the Limits of Acceptable
Change Committee. How many more jet boats could the river stand? Could
airports fit within the "limits of acceptable change?" How many
domestic sheep allotments are compatible with Bighorn Sheep in Hells
Canyon? What is the minimum acreage of roadless areas in Montana that
must be protected to constitute a Wilderness bill? Rachel Carson asked
a different, more appropriate question in SILENT SPRING: "Who would
want to live in a world which is just not quite fatal?" Land managers
and users need to focus on what the natural world needs and what our
options are for living in accordance with those needs. As Aldo Leopold
wrote in SAND COUNTY ALMANAC, "The practices we now call conservation
are, to a large extent, local alleviations of biotic pain. They are
necessary, but they must not be confused with cures. The art of land
doctoring is being practiced with vigor, but the science of land health
is yet to be born."

4. Land management risk assessors assume they can define acceptable
damage for society. In the March 1992 edition of the Northern Region
Forest Service paper called "Our Approach to Sustaining Ecological
Systems," the Forest Service says that the Desired Condition (DC) of a
landscape at any scale must account for the goods, services and
amenities desired by society." Who is "society?" What "society" demands
salvage logging? What amenities will our children want? The risk
assessors in some environmental groups ask, "What level of conservation
is acceptable to our members? To our granting foundations and
corporations?" Land managers need to face their responsibility to
advocate for the land and educate the public regarding the benefits of
behaving well toward the land. Instead of acting as if they know what
da-mage is acceptable to society, they need to sell the public and
Congress on the social, environmental, spiritual, and economic benefits
of wildlands.

5. Land management risk assessors focus on business-as-usual rather
than business-as-environmentally-responsible. Again, risk assessors do
not look at how our society might treasure, and benefit from forests
that are whole and wild. They do not look at the best forestry that
could be done. They do not present the uses of our National Forests
that would be least damaging, most protective, most restorative.
Instead, they look at business-as-usual: They uphold timber, grazing,
and mining interests. Land managers need to constantly search for the
most environmentally responsible alternatives for behaving on public
and private lands. The Forest Service and environmental organizations
need to go beyond looking at incremental improvements in mining,
grazing, predator killing, and tree cutting. They need to
systematically consider what behaviors are truly compatible with
diverse plant life, clean water, recovering fish populations, and
silence. In all of our work with the Northern Rockies lands and
peoples, we need to reject the process of figuring out the limits of
acceptable degradation. We need to reject the current dominant role
held in our society by risk assessment and replace it with alternatives
assessment. We need to take the high scientific, ecological, political,
and moral ground and advocate for the best possible behaviors of people
toward the Earth. Always.

Mary O'Brien has a Ph.D. in botany. From 1983 to 1990 she served as
staff scientist for the Northwest Coalition for Alternatives to
Pesticides in Eugene, Oregon and during the same period she edited the
Coalition's quarterly JOURNAL OF PESTICIDE REFORM. She is president of
the board of directors of the international Pesticide Action Network
(PAN) in San Francisco, CA. Later this year, Dr. O'Brien will join the
staff of Environmental Research Foundation as staff scientist.